SHELL LUBRICANTS DISTRIBUTOR LEARNING SYSTEM – DATA PROTECTION POLICY

We respect the privacy of everyone who visits https://shelllubricantsdistributorslearning.niit-mts.com. Please read the following privacy policy (referred to as the "Privacy Policy" throughout this learning system) carefully, so that you can understand how we collect and use the personal information that you provide to us. By accessing the learning system, you will be treated as having given your permission for disclosures referred to in this Privacy Policy.

What does this Privacy Policy cover?

This Privacy Policy covers the use of your personal information which is collected through or in connection with the learning system accessed at https://shelllubricantsdistributorslearning.niit-mts.com.

Who is responsible for the personal information collected on the learning system?

Shell International Petroleum Company Limited (referred to on this learning system as "Shell" "we", "us" or "our") is a company registered in England and Wales under company number 00621148, VAT registration number GB 235 763 255 (000), and registered office at Shell Centre, York Road, London SE1 7NA, and controls the personal data collected on the learning system.

Information Collection and Use

We will collect personal information including your name, email address, role, company, employer and location in order to:

• set up user accounts for you in the learning system;
• offer you training courses within the learning system;
• provide your training results to you, your employer and/or individuals within the Shell Group of companies who are from time to time designated as training managers;
• respond to queries or requests submitted by you; and
• administer or otherwise carry out our obligations in relation to any agreement you or your employer has with Shell.

Personal data is handled and protected in accordance with applicable data protection laws and relevant Shell policies and rules.

If at any time you wish us to stop using your information for any or all of the above purposes, please contact us as set out below. Upon receipt of such a request, we will stop the use of your information for such purposes as soon as it is reasonably possible to do so.

Data Controller

Shell International Petroleum Company Limited is the data controller for the purpose of the Data Protection Act 1998.

Other Jurisdictions and Third Parties

Except as set out in this Privacy Policy, we will not disclose any personal information to any third party without your permission unless we are legally entitled or required to do so (for example, if required to do so by legal process or for the purposes of prevention of fraud or other crime), or if we believe that such action is necessary to protect and/or defend our rights, property or personal safety and those of our users/customers, etc.

Shell will ensure that your personal data is protected in accordance with the applicable data protection legislation and the Shell Group Data Privacy Manual. Data may be transferred to countries outside of the European Economic Area (EEA). By way of example, this may happen if any of our servers are from time to time located in a country outside of the EEA or one of our service providers is located in a country outside of the EEA. These countries may not have similar data protection laws to the EEA. If we transfer your information outside of the EEA in this way, we will take steps to ensure that your privacy rights continue to be protected. In addition, if you use our services while you are outside the EEA, your information may be transferred outside the EEA in order to provide you with those services.

Shell uses a company called NIIT Limited to provide certain aspects of the learning system services which is acting as a data processor on behalf of Shell. NIIT Limited is a company registered in India, with its registered address at 8, Balaji Estate, Sudarshan Munjal Marg, Kalkaji, New Delhi – 110019. Data provided to NIIT will be processed in the USA. Shell will ensure that your personal data remains protected in accordance with applicable data protection legislation and relevant Shell policies and rules, when it is transferred to NIIT Limited and/or to any other third parties as may be appropriate.

Cookies

Please note that the learning system uses cookies. Cookies are small text files which are stored on your computer by a website and which distinguish you from other users. The learning system uses cookies for quality control and security purposes and to make your use of the site quicker and easier. Cookies can be disabled in your browser settings. More information on the learning system’s use of cookies is available https://shelllubricantsdistributorslearning.niit-mts.com/educate/shelllubricants/cookiepolicy.html

Security of Your Personal Data

All information you provide to us is stored on secure servers. We have implemented technology and policies with the objective of protecting your privacy from unauthorised access and improper use and will update these measures as new technology becomes available, as appropriate.

Retention

For the purposes described above, your personal data will be retained within the learning system by Shell as long as you continue to access the system. If you do not access the learning system for a period of one year, then your user account will be automatically deactivated in the system, and your personal data will be deleted. Objections to the retention of personal data can be sent to contact persons mentioned at the end of this document.

Keeping Our Records Accurate

We aim to keep our information about you as accurate as possible. If you would like to review or change the details you have supplied us with, please contact us as set out below.

Will this Privacy Policy change?

From time to time we may make changes to this Privacy Policy. If we make any substantial changes to this Privacy Policy and the way in which we process your personal data, we will post these changes on this page and will do our best to notify you of any significant changes. Please check our Privacy Policy on a regular basis.

Consent

By using our learning system you are consenting to the processing of the personal data that we collect from you in accordance with this Privacy Policy. Please address any questions, comments and requests regarding our data processing practices to the contact persons mentioned at the end of this document.

By entering the learning system you:

1. Declare that you have read, understood and accepted the statements set out in this Privacy Policy; and
2. Declare that the username and password you will use / have used to access the learning system are your own and were not issued to a third party; and
3. Give your consent to the processing of your personal data in accordance with this Privacy Policy.

How You Can Contact Us

If at any time you would like to contact us, you can do so by any of the following means:

• Contact your Shell Learning Manager; or
• Send an email to us using details in the Contact Us.

SHELL LUBRICANTS DISTRIBUTOR LEARNING SYSTEM – TERMS AND CONDITIONS OF USE

The Shell Lubricants Distributor Learning System (the “Learning System”) provides external business partners an online platform that offers training material and learning solutions. The Learning System is found at https://shelllubricantsdistributorslearning.niit-mts.com.

Operator of this Learning System

Shell International Petroleum Company Limited (referred to on this Learning System as "Shell" "we", "us" or "our"). Shell International Petroleum Company Limited is a company registered in England and Wales under company number 00621148, VAT registration number GB 235 763 255 (000), and registered office at Shell Centre, York Road, London SE1 7NA.

Terms and Conditions governing the Learning System

Please read the following information carefully. Your use of the Learning System will indicate your agreement to these terms and conditions of use ("Terms"). If you do not agree to be bound by these Terms, please do not use the Learning System. You should print a copy of these Terms or save them to your computer for future reference.

You may

• access any part of the Learning System;
• print off one copy of any or all of the pages for your own personal reference, as you are expressly authorised to so by Shell.

You may not

• copy (whether by printing off onto paper, storing on disk, downloading or in any other way), distribute (including distributing copies), broadcast, alter or tamper with in any way or otherwise use any material contained in the Learning System except as set out under "You may". These restrictions apply in relation to all or part of the material on the Learning System;
• remove any copyright, trade mark or other intellectual property notices contained in the original material from any material copied or printed off from the Learning System;
• link to the Learning System without our express written consent.

If you print off, copy or download any part of the Learning System in breach of these Terms, your right to use the Learning System will cease immediately and you must, at Shell's option, return or destroy any copies of the materials you have made.

Access to the Learning System

Access to the Learning System is permitted on a temporary basis. Shell reserves the right to suspend, withdraw or amend any aspect of the Learning System, including the availability of any features, information or content, or to restrict access to all or part of the Learning System without notice and without liability.

Compatibility of this Website with Your Hardware and Software

Shell does not represent or warrant that the use of this Learning System or of any file or programme available for download and/or execution from or via this Learning System will be compatible with all hardware and software that may be used by you and excludes any liability in contract, tort (including negligence), breach of statutory duty, restitution or otherwise for any damage, indirect or consequential loss (including without limitation pure economic loss, loss of profit, loss of business, depletion of goodwill and like loss) howsoever caused arising out of or in connection with the use of this Learning System, or the use, accessing, downloading of any information, including without any limitation, as a result of any computer virus, error, defect or suchlike.

Changes to/Operation of the Learning System

Shell may change the format and content of the Learning System at any time. We will do everything possible to ensure the continued availability of the Learning System, but we may need to suspend the operation of the Learning System for support, upgrades or maintenance work, in order to update the content or for any other reason. Shell reserves the right to terminate access to the Learning System at any time and without notice. Shell will not be liable if, for any reason, the Learning System is unavailable at any time or for any period.

Security

You must treat your username and password and any other information you are provided with as part of Shell's security procedure as confidential, and you must not disclose it to any third party, nor allow any unauthorised person access to the Learning System under your username and/or security password. Shell has the right to disable any username or password, whether chosen by you or allocated by it, at any time, if, in the opinion of Shell, you have failed to comply with any of the provisions of these Terms.

Confidentiality

You acknowledge and agree that the content, information, and advice contained in or provided via the Learning System are confidential to Shell. You agree to maintain such content, information and advice in strict confidence and not to disclose or provide access thereto to any unauthorised person or entity.

Intellectual Property Rights

The Learning System contains material including text, photographs and other images and sound, which is protected by copyright and/or other intellectual property rights. All copyright and other intellectual property rights in this material are either owned by Shell or have been licenced to it by the owner(s) of those rights so that it can use this material as part of the Learning System. All such rights are reserved.

The Learning System also contains trademarks, including the mark "Shell" and the Shell emblem. All trademarks included on this web Learning System belong to Shell or have been licenced to it by the owner(s) of those trade marks for use on the Learning System. No licence, immunity or other right under or in respect of any intellectual property (including without limitation patent rights, copyright, registered or unregistered trademarks, database rights and rights in designs), information or technology is granted to you under this Agreement.

Liability

All information or advice provided as part of the material available on this Learning System is advisory in nature and you should not rely on it in connection with the making of any decision.

Nothing in these Terms shall limit or exclude our liability for death or personal injury caused by our negligence or for our fraud or fraudulent misrepresentation.

To the fullest extent permitted by law, we will under no circumstances whatever be liable to you, whether in contract, tort (including negligence), breach of statutory duty, or otherwise, arising under or in connection with either your use of the Learning System, or for your reliance on any information or advice contained on it for: (a) loss of actual or anticipated profit, sales, savings, use, business, business opportunity or revenue; (b) losses caused by business interruption; (c) loss of goodwill or reputation; (d) loss or corruption of data, information or software; or (e) any indirect, special or consequential cost, expense, loss or damage suffered by you in connection with your use of the Learning System, and any materials posted on it, even if such cost, expense, loss or damage was reasonably foreseeable or might reasonably have been contemplated by you and/or Shell and whether arising from breach of contract, tort, negligence, breach of statutory duty or otherwise.

To the fullest extent permissible by applicable law, you shall hold harmless and indemnify Shell, from and against any and all claims, liabilities, costs, losses, damages and expenses (including, without limitation, legal fees and disbursements) of every kind and nature resulting from your use of the Learning System or for your reliance on any information or advice contained on it.

Data Protection

Personal details provided to Shell and/or its affiliate companies through the Learning System will only be used in accordance with our Privacy Policy. Please read this carefully before using the Learning System. By providing your personal details to us you are consenting to their use in accordance with our Privacy Policy.

Trade Controls

Access to the Learning System is restricted and controlled by Shell’s policies, which govern activities that involve Generally Embargoed Countries and Highly Restricted Countries. By accepting these Terms, you agree that you are not accessing, or will not access, the Learning System from any of the listed Generally Embargoed Countries or Highly Restricted Countries. Countries classified by Shell as Generally Embargoed or Highly Restricted are: Cuba, Iran, Sudan, Syria, North Korea and Belarus. Should you require access to the Learning System from any of the listed countries, contact us prior to attempting access to the Learning System, using the information under ‘Contact Us’ below.

Changes to Terms and Conditions

Shell may change these Terms and the disclaimers set out above from time to time. By using the Learning System you are accepting that you are bound by the current Terms and disclaimers and so you should check these each time you revisit the Learning System.

Entire Agreement

These Terms and our Privacy Policy constitute the entire agreement between you and us. You acknowledge that you have not relied on any statement, promise or representation made or given by or on behalf of us which is not set out in these Terms or our Privacy Policy. Nothing in this clause shall limit or exclude any liability for fraud.

Assignment

We may transfer our rights and obligations connected with the Learning System to another organisation, but this will not affect your rights or our obligations under these Terms. You may only transfer your rights or your obligations under these Terms to another person with our prior consent in writing.

Waiver

If we fail to insist that you perform any of your obligations under these Terms, or if we do not enforce our rights against you, or if we delay in doing so, that will not mean that we have waived our rights against you and will not mean that you do not have to comply with those obligations. If we do waive a default by you, we will only do so in writing, and that will not mean that we will automatically waive any later default by you.

Severance

Each of the paragraphs of these Terms operates separately. The invalidity or unenforceability of one of these Terms will not affect the validity or enforceability of the remaining Terms.

Jurisdiction and Applicable Law

These Terms shall be governed by and to be interpreted in accordance with English law and the English courts will have exclusive jurisdiction over any dispute arising in relation to these Terms.

Contact Us

If at any time you would like to contact us, you can do so by any of the following means:

• Contact your Shell Learning Manager; or
• Send an email to us using details in the Contact Us.